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DAVID A. D. DAD,
;2oi"/i;H'0ti2:27
Petitioner, CALiENDAR/lRQOiH 09
TIHE 00=00
V.
Oenera 1 Cihancer.y
No.
CITY OF CHICAGO,a municipal
corporation, and
UNITED AIRLINES,INC., a corporation.
Respondents.
91
Petitioner, DAVID A. D. DAO,by his attorneys, CORBOY & DEMETRIOjP.C.,
GOLAN CHRISTIE TAGLIA LLP, petitions this Court for an Emergency Bill of D'racovery^nd
'Z.r~, (J\
in support thereof, states as follows: i;.
No. 3411,scheduled to fly from Chicago, O'Hare International Airport to Louisville, Kentucky.
2. After being duly processed by the ticket agent, checked in by the attendant, and
seated in his assigned passenger seat. Petitioner was forcibly dragged and removed from the said
operated Chicago O'Hare International Airport, and United Airlines, a corporation, who owned
4. Petitioner believes it is crucial and essential that the following be preserved and
(c) complete April 9,2017, passenger list for United Express Flight
No. 3411;
(d) complete April 9, 2017, employee and crew list for United Express
Flight No. 3411;
(f) the protocol of United Airlines in force and effect for the removal of
passengers from commercial aircraft as of April 9,2017; and
(g) the personnel files ofthe Aviation Department police who removed
Petitioner from the plane.
since each ofthose items are in the possession of one or both ofthe Respondents, and Petitioner
currently has no access to them and believes that serious prejudice will inure to the Petitioner if
Respectfully submitted.
Thomfc A. Demetrio
DAVID A. D. DAG,
Petitioner,
201'?CH052:27
CALEHDiAR/IRQOiH 09
TIHE 00300
No.
'15srie i'~ a 1 L-il"!a n-'Ce r
CITY OF CHICAGO,a municipal
corporation, and
UNITED AIRLINES,INC., a corporation.
Respondents.
AFFIDAVIT
I, Thomas A.Demetrio of Corboy & Demetrio,P.C., as one ofthe attorneys for Petitioner,
DAVID A. D.DAO,am familiar with the facts set forth in the Bill of Discovery.
Based upon my limited investigation to date, I state, under oath, that all ofthe allegations
are true and correct to the best of my knowledge.
Thcflnas A. Demetrio
#02329 TAD/EGW\rtp